In the Court of Hon’ble _____________-.

O.S. No.____of _____Year

-----cause title------

SUIT FOR RECOVERY OF RS ________/- ALONGWITH

INTEREST
RESPECTFULLY SHOWETH:
1. That the plaintiff is a company under the name and style of M/s
_________________________ and Mr. ______________ through
whom the present suit is being instituted is the ___________________ of
the plaintiff company and he has been authorized by the plaintiff vide
Resolution dated __________ and he is fully competent to engage the
counsel, sign the vakalatnama, plaint, application for stay, affidavit,
applications etc. to depose before this Hon’ble court and to do such other acts,
deeds and things. The copy of the Resolution is enclosed as Annexure –A.
2. That the plaintiff is engaged in the business of
_______________________________.

3. That during the course of business with the defendant the plaintiff has done
_____________________________. An agreement to this effect was
executed between the plaintiff and the defendant on _____________. The
plaintiff did the job work as per the satisfaction of the defendant. During the
course of business the plaintiff issued proper bills to the defendant, which
were accepted and acknowledged by the defendant. The copy of the Bill is
enclosed as Annexure –B.

4. That as per the statement of account maintained by the plaintiff the balance
amount of Rs. ________/- is outstanding against the defendant as on
______________ after receiving the last payment of Rs. ___________/-
on ________________. The photocopies of Agreement and statement of
account are enclosed.
5. That as per the terms and conditions of the Agreement the defendant have
to make the payment of ___% on the delivery of the ____________, which
was supplied to the defendant in time but the payment was not made by the
defendant upto ____________. Thereafter so many requests were made to
the defendant to make the payment so as the work could be done in time but
the defendant failed to make the payment. It is no out of place to mention here
that the work was delayed due to the reason known to the defendant. The
defendant violated the terms and conditions of the Agreement.

6. That the account of the defendant became irregular and inspite of repeated
requests and demands the defendant failed to regularize their account and
also failed to make the payment in time.

7. That the plaintiff requested the defendant several times to make the
payment of the outstanding amount which is lying against them but the
defendant on one pretext or the other avoided to the legitimate requests of the
plaintiff without any cause or reason and has stopped the payment of the
plaintiff. In this contest the plaintiff has so many times orally and in writing
approached the defendant to make the payment of the outstanding amount
lying with the defendant. the notice was sent to the defendant by the plaintiff
but the defendant failed to make the payment thereafter the and wrote a letter
stating that the account of the plaintiff is debited with Rs.
______________/- without any reason. The defendant is trying to make
liable the plaintiff for their wrongs. The defendant issued the same to cheat
the plaintiff. The defendant are evading and neglecting the payment of the
plaintiff with one false pretext or the other and with some ulterior purpose
and motives therefore, the plaintiff can not trust on the defendant any more
and cannot and cannot wait for an indefinite period hence they have been
compelled to take efficacious legal action against the defendant.
8. That the account of the defendant become irregular and inspite of repeated
requests and demands the defendant failed to regularize their account and
also failed to make the payment in time.

9. That the plaintiff was induced by the defendant to believe in making false
representations that they would honour the payment on receipt of the invoice
but plaintiff realized letter that the intentions of the defendant was not clear
and became decisive, the defendant after receiving the goods, converted the
same in their own use and still the defendants have not paid the money to the
plaintiff as assured by them.

10. That the defendant fraudulently and dishonestly induced the plaintiff to
deliver their property and as such the defendant deceived the plaintiff and
caused wrongful loss. The defendant were bound to protect the interest of the
plaintiff but the defendants failed to do so hence the defendant have
committed an offence punishable under section _______________ IPC and
other provisions of the law.

11. That as per the initial terms and conditions settled with the defendant by
the plaintiff, the plaintiff is entitled for an interest @ ___% per annum which
is the prevailing rate in the market usage and is the banking rate of interest on
outstanding. The plaintiff claims interest at the above rate from the defendant
it became due till the date of realization.

12. That plaintiff served a legal Notice dated ____________ through

registered post upon the defendant calling upon them to make the payment of
Rs. ________/- along with interest @ __% per annum which was duly
received by the defendant. On the receipt of this notice the defendant
contacted with the plaintiff and demanded some time for making the payment
because the defendant were facing some financial problems. But on
___________ refused to make any payment to the plaintiff.

13. That the cause of action to file the present suit accrued on each and every
date when the plaintiff requested the defendant to make the payment of the
outstanding amount due against the defendant. The cause of action further
accrued on ____________ when the plaintiff sent a legal Notice to the
defendant calling upon to make the payment of the plaintiff outstanding
against the defendant. The cause of action finally accrued in favour of the
plaintiff and against the defendant on _________ when the defendant
refused to make payment of the same to the plaintiff. Hence
_____________ is the final date of cause of action accrued in favour of the
plaintiff and against the defendants. Hence this suit.

14. That the present suit being filed by the plaintiffs against the defendant is
the first suit and no such suit has been previously filed, pending or decided by
any court of law on the same subject matter.

15. That plaintiff and the defendant reside and the and entire cause of action
also accrued between the parties at ____________, within the territorial
jurisdiction of this Hon’ble court, therefore, this Hon’ble court has got the
jurisdiction to entertain and try the present suit
16. That the value of the suit for the purposes of court fee and jurisdiction is
assessed at Rs. ____________/- upon which Advolrum Court fee Stamp of
Rs. ________/- has been affixed on the plaint.
It is, therefore, prayed that this Hon’ble court may graciously be pleased
to pass

(i) a decree for recovery of Rs. ________/- alongwith interest @ __% per
annum since _________ till upto date may kindly be passed in favour of the
plaintiff and against the defendant

(ii) costs of the suit may be awarded in favour of the plaintiff and against the
defendant

(iii) or any other relief which this Hon’ble court deems fit and proper may
kindly be granted in favour of the plaintiff and against the defendant
PLAINTIFF

Advocate

VERIFICATION:
Verified that the contents of Paras No.___________ of the plaint are true
and correct to best of my knowledge and Paras No. ___________ of the
plaint are true to best of my knowledge and belief.

Verified at __________ on___________

PLAINTIFF